MEMORANDUM OPINION
ARTHUR J. SPECTOR, Bankruptcy Judge.
There are no material disputes as to the facts involved in this case; the statement of facts comes from the government's brief in support of its motion for summary judgment, which the plaintiff adopted in his brief in support of his motion for summary judgment. The debtor and his wife did not file their federal income tax returns for the years 1969 through 1974 until December 15, 1977. Between February...
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